p.1 

OAR Box 1490 

Prepped by Charmelle Mathews 

Document Number: 

5DIV-C-24 

Docket Number: 

A-94-52 

Printed 8/4/2008 11:51:47 AM Sheet 51 of 273 
P.2 

PES 

A MACTEC COMPANY 

Pacific Environmental! 

5001 South Miami Boulevat 

P.O. BOX 12077 

Research Triangle Park, NC 27709 

A-94-52 

IV-C-24 

Office: 919/941-0333 Fax: 919/941-0234 

Home Page: www.mactec.com 

March 28,2002 

Mr. Kenneth Witt 

Able Body 

Phone: 417-623-3060 

FAX: 417-623-4617 

Dear Mr. Witt: 

j \\\ 

MAR 2 8 2002 |// j 

As you know, Pacific Environmental Services, Inc., (PES) is the contractor to the U.S. 

Environmental Protection Agency (EPA) on the reinforced plastic composites (RFP) NESHAP. 

PES is currently assisting the EPA in preparing responses to public comments received on the 

proposed RFP NESHAP. Several comments letters identify facilities that are not currently in our 

database, including your two facilities in Missouri. Attached is a table that we would like Able 

Body to fill out in order for us to appropriately include these facilities in our database. I have 

filled in as much information as I could based on your comment letter for each facility on 

separate tables. Please review this information and correct it as necessary and then please fill in 

all remaining information. Please note that some ofthe information I have entered is incomplete 

(e.g., under "Process Grouping" I have entered "open molding, mechanical" but have not 

indicated if it is corrosion-resistant or non-corrosion resistant, or if it is filled or unfilled). Where 

information is accurate, but incomplete, please be sure to complete the information. I have tried 

to limit the information requested to that necessary for us to evaluate each facility's ranking and 

then to allow us to cost various control options. 

I have also attached a list of questions concerning your comment letter. I will call you 

next week (either Tuesday or Wednesday) to discuss these questions. 

If you have any questions concerning this request, please do not hesitate to contact me at 

919-941-0333 or the EPA Project Lead, Mr. Keith Barnett, at 919-541-5606. Please feel free to 

call him if you have any questions. If any ofthe information you can supply is considered to be 

confidential by your company, we can provide you with the procedures that are used to submit 

such information directly to the EPA. Thank you in advance for whatever help you can provide. 

Sincerely, 

Kenneth R. Meardon 

PACIFIC ENVIRONMENTAL SERVICES, INC. 

Enclosures (2) 
Facility Name and Location: ^cUiffid-gck-^ Jo^ \ ,>s, Hfcsot^l 

Hours of Operation: ^ooo 

Year for Which Data Is Being Reported: Iooo 

\fi 

FACILITY SURVEY TABLE 

Process Grouping 

Examples 

Open molding, mechanical 

Open molding, 

mechanical, non-corrosion 

resistant, filled 

0$l)\ Mto\*A.fA0-y 

Mcby&wicaS. 

C\oSeA H*43l<UV\C\ 

Material 

pigmented gel coat 

vinyl ester resin 

r«**v\ 

^Ogyfyectleo aA COOJL~ 

Quantity 

Used (tpy) 

500 

1000 

•4Zo 

12.0 

Average HAP 

Content 

(wt. %) 

46 

32-37 

Application 

Technique 

spray 

mechanical, non-atomized 

(100%) 

Cico«7o^ 

Other Emission 

Reduction 

Technique 

none 

incinerator (90% overall 

capture and control) 

Color 

(gel coat 

only) 

offwhite 

NA 
Facility Name and Location: $dA*(fere*U<^W, 5q*A •*;}\&sout i Page 2. 

Process Grouping Material Quantity 

Used (tpy) 

Average HAP 

Content 

(wt. %) 

Application 

Technique 

Other Emission 

Reduction 

Technique 

Color 

(gel coat 

only) 

V 

bs 
Facility Name and Location: 

Hours of Operation: 4oo*o 

Year for Which Data Is Being Reported: 2.COO 

FACILITY SURVEY TABLE 

in 

Process Grouping 

Examples 

Open molding, mechanical 

Open molding, 

mechanical, non-corrosion 

resistant, filled 

-tOd\(v«\ r€6»v\ 

-tOe>lt>«\ °yA 00*7" 

Material 

pigmented gel coat 

vinyl ester resin 

f**^ 

Quantity 

Used (tpy) 

500 

1000 

qzo 

-70 

Average HAP 

Content 

(wt. %) 

46 

32-37 

Application 

Technique 

spray 

mechanical, non-atomized 

(100%) 

Other Emission 

Reduction 

Technique 

none 

incinerator (90% overall 

capture and control) 

Color 

(gel coat 

only) 

offwhite 

NA 
Facility Name and Location: "7 -~LXV&-J!TP>P\IV,

\J tAiSSotvi Page 2 

^ 

Process Grouping Material Quantity 

Used (tpy) 

Average HAP 

Content 

(wt. %) 

Application 

Technique 

Other Emission 

Reduction 

Technique 

Color 

(gel coat 

only) 

Tl 

cn 
P.7 

Instructions for New Facility Survey Table 

Facility Name and Location: Please enter the name used to refer to the facility for which the data are being reported 

and the physical location ofthe facility. 

Year for Which Data is Being Reported: Please use the most recent year for which you have the requested 

information. If that year is not representative ofyour production, then report a year that you consider representative. 

Hours of Operation: Please report the hours of operation for the year that corresponds to the data being reported. 

For example, the data in the table is for the year 2000, report the hours of operation for the year 2000, even ifthe 

hours of operation at which you are currently operating are different. 

Process Grouping: Select from the following list: 

manual, corrosion-resistant 

manual, non-corrosion resistant 

tooling resins, manual application 

mechanical, corrosion-resistant 

mechanical, non-corrosion resistant, unfilled 

mechanical, non-corrosion resistant, filled 

tooling resin, mechanical 

corrosion-resistant filament winding 

non-corrosion resistant filament winding 

pigmented production gel coats 

clear production gel coats 

tooling gel coats 

closed molding (compression and injection molding) 

resin transfer molding 

corrosion-resistant centrifugal casting 

non-corrosion resistant centrifugal casting 

continuous lamination/continuous casting 

polymer casting 

pultrusion 

SMC manufacturing 

BMC manufacturing. 

Material: Indicate the type(s) of gel coats and resins being used. If readily available, provide information on an 

individual gel coat and resin basis. 

Usage: List amount used in a representative year by group. If individual gel coats or resins are listed, then provide 

the amount used for each individual gel coat and resin reported. 

HAP Content: Include all HAP monomer (styrene, MMA, etc.) for when the material is applied. This would 

include any HAP added to the purchased resin or gel coat. If average weight percent is not readily available, show 

range. 

Application Technique: List each application technique used to apply the gel coats and resins. Include in 

parentheses after technique the percentage of each material applied using that technique. 

Other Einission Reduction Technique: If you use add-on controls or any other technique to can be quantified for 

reducing emissions, please list and then show in parentheses the overall capture-and-control effectiveness. 

Color (gel coat only): For gel coats only, indicate for each gel coat one ofthe following: white/off white pigmented, 

other pigmented; or clear. 

7 
P.8 

ENCLOSURE 2 

LIST OF QUESTIONS ON SEPTEMBER 27,2001 COMMENT LETTER 

1. On page 13, average styrene exhaust concentrations of "00" ppm are shown. It seems like 

their should be values above zero shown. 

2. For Table 2, what flow rates were used in developing the cost estimates? Those shown on 

page 7? 

3. How were the emission reductions calculated to obtain the emission reductions used to 

calculate cost effectiveness values in Table 2? For example, I calculated the tons of emission 

reduction needed to obtain the Year 2000 cost effectiveness values. For Schifferdecker, this is 

98.5 tons and for 7th Ave this is 54.8 tons. At 95% capture-and-control, I get different values. 

For example, for Schifferdecker, I get 0.95 x 108 tpy in Year 2000 = 102.6. 

4. What were the calculations used to estimate the Year 2000 emissions? 

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